Privacy Notice for California Residents

Last updated: 25 July 2025

INTRO

This Privacy Notice applies to Consumers residing in California (hereinafter the “California Privacy Notice” or “Notice”), under the California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq. This notice supplements our Privacy Policy (the “Privacy Policy”) by explaining your rights under the CCPA and it provides certain mandated disclosures about treatment of California residents’ information, both online and offline.

Capitalized terms used but not defined in this Privacy Notice will have the meanings set out in the Tulip’s Privacy Policy and/or our Terms of Use (“TOU”). If there is any conflict or inconsistency between the terms of this Notice and the Privacy Policy and/or the TOU, the terms of this Notice will govern.

The terms “personal information”, “business purpose”, “commercial purpose”, “sale”, “service provider” and “third parties” as used in this Notice have the meanings ascribed to them in the CCPA.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

In the preceding 12 months, we have collected the following categories and types of personal information:

  • Contact information provided by our Users.
  • Contents of Users’ interaction with out customer support.
  • Identifiers of our Customer Admins and End Users, such as name, email addresses and billing addresses.
  • Technical Identifies, such as IP address.
  • Activity on our Website, such as clickstream and engagement with our Website properties.
  • Users’ browsing journey from and to our Website.
  • Inferences, which are drawn from the above information to enhance the Services and customize content and functionality.
  • Characteristics of job applicants, such as gender, age, education and employment history, only if provided by User and pursuant to Section 13 of our Privacy Policy.

2. THE SOURCES OF PERSONAL INFORMATION

The sources from which we obtain personal information are:

  • Directly from our Users (either actively or through monitoring of use of the Website),
  • Social networks with whom Users hold an account through which such Users register to our Services
  • Third parties who assured us that they have obtained Users’ consent for such provision of information

‍3. THE PURPOSE FOR COLLECTING AND SHARING INFORMATION

  • In the course of using the Tulip Services, we may collect and process the following categories of information
    • Email Address: Provided during registration or login and used for identity, communication, and account management.
    • User ID: An internal identifier assigned to each user to manage sessions, associate activity within the Services, and support analytics and troubleshooting.
    • IP Address: Collected automatically during use of the Services to support security, regional compliance, and performance monitoring.
    • Operating System & Browser Version: Automatically collected to help ensure compatibility, improve user experience, and detect technical issues. This includes OS name and version (e.g., MacOS 14.5) and browser details (e.g., Chrome 125.0).
  • This information is processed to:
    • Operate, maintain, and improve the Services;
    • Support security features and detect abuse;
    • Diagnose technical issues;
    • Personalize and optimize the user experience;

We do not sell this information as defined under the CCPA. Any third-party service providers processing this data do so strictly on our behalf and in accordance with our Privacy Policy.

4. PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

We collect and share personal information for the following purposes: registering Users to our Services, administering the provision of our Services and billing where applicable, authenticating Users access request when they log-in to our Services, providing customer support, detecting and preventing security incidents, debugging and fixing errors, maintaining and enhancing our Services, allowing Users to receive our newsletters when they have agreed to receive them, marketing our Services and attributing registration to and engagement with our Services to the applicable marketing campaigns.

We do not put your data on the open market, act as data brokers or otherwise trade in your data. However, certain standard generally accepted business practices maybe deemed as “Sale” of data under the CCPA, such as when we utilize third party service providers that provide us with services, while they retain certain ability to use your data for their own business needs (e.g. Google Analytics and Facebook).

If you are a California customer, you have a right under the new definition of “sale”, to request to opt-out of certain data transfers and sharing of personal activities which we operate. Please refer to section 4, “Your California Consumer Rights”, below for information on how you can exercise your rights.

For more details on how and to whom we share your data please refer to Section 6 of our Privacy Policy.

5. WITH WHOM DO WE SHARE DATA?

5.1. RIGHT TO ACCESS

California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request up to two times in a 12-month period.  

5.2 RIGHT TO REQUEST ADDITIONAL INFORMATION

If you are a California consumer, you may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell your personal information, the categories of personal information we have disclosed and “sold” about you in the preceding 12 months, and the categories of third parties to whom we sold personal information in the preceding 12 months

5.3 RIGHT TO DELETE

If you are a California consumer, you also have the right to request deletion of your personal information, subject to certain applicable legal exceptions.

5.4 RIGHT TO OPT OUT OF SALE OF PERSONAL INFORMATION

If you are a California consumer, you have the right to opt-out of sales of personal information and to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights (unless permitted by applicable law, such as if the differences are reasonably related to your information).  Our Privacy Policy [please make a link] describes the limited circumstances in which we may share your information with third parties.

5.5 HOW TO MAKE A CCPA REQUESTS?

To make an access request, a deletion request or an “opt-out” of the “sale” request (as described above), please email us at privacy@tulipsecurity.com. Before completing your request, we may need to verify your identity or the identity of your authorized representative. We may send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity. You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA.

6. CONTACT US

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:

If you wish to receive more information on these Terms, please contact us at privacy@tulipsecurity.com